OECD Model Tax Convention 2025: New guidelines on permanent establishment and remote work

On November 18, 2025, the OECD approved the 2025 update of the OECD Model Tax Convention. One of the most relevant changes for multinational enterprises concerns the updated commentary on Article 5 (Permanent Establishment), which addresses the growing reality of cross-border remote work. Although existing tax treaties are not automatically amended, tax authorities and courts […]

CbC Notification Requirements in Belgium: Action Required?

Belgian companies and permanent establishments that are/were part of a multinational group with consolidated turnover exceeding 750 million EUR must ensure compliance with Country-by-Country (CbC) notification requirements. Specifically, if the group’s financial year ends on December 31, 2025, Belgian entities need to assess whether a CbC notification is required – regardless of their own financial […]